Business services have typically been the first to be exposed to competition. Enterprises have endorsed and embraced competition and choice long before alternatives were even available for residential users. According to the CRTC’s statistics, competitors for business services have captured 14% of the local market, double the share of competitors for residential services (7.6%).
For these reasons, it was not surprising that the proposed criteria for business services forbearance announced on Monday were lighter than those for residential. In the case of residential services, the Minister is proposing the existence of competition from an alternate wireline provider (eg. the cable company) plus an independent wireless service provider. For business services, there needs to be an independently owned, facilities-based wireline competitor, offering local telephone services throughout that market.
What does it mean to offer facilities-based competitive local telephone services throughout a geographic market?
For residential services, given the ubiquity of Canadian cable companies, it is somewhat understandable that residential competition either exists or it doesn’t in a given geographic area.
Business services are very different. Cable companies generally do not have appropriate telephony facilities ‘throughout’ business locations. Facilities-based competitive access to buildings, corporate campus locations, industrial parks, etc. can be spotty. For optical-based data services, we have written in the past that there is no incumbent advantage; but voice grade services are a different situation.
On one hand, we can see that competition for business services is vibrant; on the other hand, it is not clear that competitors have ubiquitous facilities-based access.
This is why access to wholesale services are so important. It is precisely why wholesale quality of service performance is the second leg of the forbearance test.
How do we ensure that the forbearance test and conditions continue to enable this to flourish? How do we define an appropriate and clear assessment of an ability to offer business services throughout a market, to identify when that market is ready to be forborne?
This will likely be among the most important areas of input to Industry Canada’s consultation process currently underway.